Simpson HCP Provides Inadequate Safety Net For Salmon

Eugene, Ore. — An independent scientific review finds that the habitat conservation plan (HCP) proposed by the Simpson Timber Co. does not provide an adequate safety net for the salmon.  “An HCP is a deal in which the government provides legal assurances to the timber company, and the timber company provides conservation assurances to the fish,” said David Bayles, conservation director for the Pacific Rivers Council.  “But these conservation assurances aren’t good enough.”

Plan summary
The Simpson HCP for 261,000 acres of timberland in western Washington seeks exemptions from both the Endangered Species Act and the Clean Water Act. If granted it would give Simpson a 50-year incidental take permit for four threatened or endangered species (marbled murrlet, bald eagle, Puget Sound chinook salmon and Hood Canal summer run chum).  The plan also covers 47 unlisted species.

Scientific analysis
The Pacific Rivers Council asked three noted scientists to review the Simpson plan:

 - Dale McCullough, senior fisheries scientist, Columbia River Intertribal Fish Commission
-  Dave Montgomery, geologist, University of Washington
-  Sherri Johnson, stream ecologist, Oregon State University.  

They found that while the stated ecological objectives of the plan are generally adequate, the steps to achieve those goals fall short of what is needed.  For example, the plan assumes there is a safe way to harvest in landslide prone areas.  Geologist Dave Montgomery writes, “I know of no studies by reputable scientists that demonstrate that a 50 to 100 percent harvest on potentially unstable slopes will not increase the probability of slope failures above ‘natural’ levels.”

Simpson’s adaptive management plan is supposed to insure against unforeseeable consequences, yet there is an arbitrary cap on acreage where management can be adjusted and how money spent. In addition, triggers for review of most prescriptions are 10 to 20 years out, and it is unclear what science backs them up. Montgomery says, “The problem is that if things fall apart at a fast enough rate, then under this plan you could have no net improvement inconditions if the budget to repair new failures exceeds the allowable maximum.”

The plan provides inadequate protection for smaller, intermittent streams and for steep, unstable slopes.  In short, the plan lacks the necessary scientific justification and puts the salmon and other species that rely on this plan at unacceptable risk.